Mohamad v. Palestinian Authority

Summary

The Supreme Court held that the term 'individual' as used in the Torture Victim Protection Act of 1991 encompasses only natural persons, so the Act does not impose liability against organizations, and it affirmed the dismissal of TVPA claims against the Palestinian Authority and the Palestine Liberation Organization. Relying on the word's ordinary meaning, the Dictionary Act's distinction between 'individuals' and artificial entities, and the statutory context — including the Act's five uses of 'individual' in a single liability sentence and its use of the broader term 'person' for wrongful-death claimants — the Court concluded that Congress created a cause of action against natural persons alone and that petitioners' purposive argument could not overcome the plain text. Justice Breyer concurred, agreeing with the judgment but reasoning that the word 'individual' alone does not decide the case and that the legislative history supplies the necessary confirmation.